The Wilderness Society’s submission relating to wood supply impacts of Gunns proposed pulp mill for the ANZ Bank’s assessment. December 2007 Tombstone Creek, Northeast Tasmania. Before logging in 2003 and after logging in 2006. Photos: Rob Blakers 2 CONTENTS 1. Executive Summary 3 2. Introduction 4 3. Background 7 4. Gunns’ pulp mill 16 5. Intensification of forestry operations in Tasmania as a result of the pulp mill. 21 6. Impact of pulp mill on climate change. 26 7. World Heritage. 28 8. Recommendations 32 Appendix 1: Documented World Heritage values of threatened forests. 33 Appendix 2: Reports on threats to the integrity of the Tasmanian World Heritage Area. 35 Appendix 3: The pulp mill: The forgotten issue is wood supply, by Dr Chris Beadle. 37 3 1. Executive Summary Gunns Ltd’s forestry activity is currently responsible for large scale destruction of Tasmania’s irreplaceable forests, the poisoning of native wildlife, and massive greenhouse gas emissions. Gunns’ proposed pulp mill will drive ongoing destruction of Tasmania’s native forests. At start-up 80% of the wood for the mill will come from carbon-dense native forests which are critical habitat for endangered species and protect water catchments important for domestic and agricultural water supply. There are no guarantees that the pulp mill will make the transition to using plantations. However, even based on Gunns’ unrealistic projections, the pulp mill would still consume over 200,000 hectares of native forests. The logging of such a huge area would cause an increase in Australia’s greenhouse gas emissions of around 2%. While there are a range of recognised environmental problems with the proposed pulp mill, including air pollution, smell and the impact of toxic effluent on the marine environment, this submission focuses only on forestry and climate change issues and the critical problem that the impact of the mill on these areas has never been assessed. Nor has there been an assessment of the mill’s negative impacts on other industries such as fishing, farming, tourism and wineries. The Wilderness Society believe that Tasmania’s native forests should be protected as carbon sinks, endangered species habitat, water catchments and for their scenic and wilderness values. The ANZ bank should not fund Gunns’ proposed pulp mill as it would lock in environmentally and socially destructive logging practices for generations to come. Gunns has refused to amend or change the project despite intense and widening concern expressed in the Tasmanian and Australian community, by independent pulp mill experts such as Dr Warwick Raverty and by groups such as the Australian Medical Association, Investors for the Future of Tasmania and The Wilderness Society. In these circumstances, and with crucial issues like the impact on forests and climate change unassessed and officially ignored, the ANZ should not fund this mill. Instead we request that the ANZ lead a process to encourage a transition of Gunns plans and operations to ensure sustainable forestry and environmental protection. 4 2. Introduction Tasmania has the tallest hardwood forests on Earth, with trees reaching nearly 100 metres and over 400 years old. These occur along the eastern fringe of the South-West Wilderness World Heritage Area, and are recognised as having World Heritage values. Tasmania has Australia’s greatest tract of temperate rainforest – in the little-known Tarkine wilderness in the north-west of the state. Northern and eastern Tasmania contains significant tracts of dry-sclerophyll eucalypt forest that are important to biodiversity, water supply and community. Climate change has sparked a flurry of interest in the large carbon storage capacity of forests and the high levels of emissions on logging of these carbon banks. Tasmania also has some of Australia’s most destructive logging practices. Thousands of hectares of native forest are clearfelled and burnt each year. Between 10 000 and 15 000 hectares have been cleared and converted to plantation every year since 1998. Much of this destruction is subsidised by the Australian taxpayer. Tasmania exports more than double the amount of woodchips than all other states of Australia put together. An alarming amount of this is sourced from high conservation value native forests. Logging is destroying Tasmania’s tall forests, its rainforests and its wilderness areas; it directly costs the taxpayer money and is having a serious detrimental effect on community cohesion. The Wilderness Society has been campaigning for the protection of Tasmania’s wild places, in particular her forests, for decades. Parallel with this campaign of protection, The Wilderness Society has called for reform of the timber industry to move away from a dependence on woodchipping, to stop logging high conservation value forests and to be economically self sufficient and not reliant on public subsidies. While some forest areas have been protected, the industry continues to destroy vast areas of identified high conservation value forest, to be heavily woodchip dependent and to continue to draw on subsidization from the public purse. As the ANZ has been the banker for Gunns since 1995, The Wilderness Society believes the bank currently plays an important role in the mismanagement of forests and forestry in Tasmania, but can reverse that by playing a role in the transition to sustainable forestry and environmental protection. The Wilderness Society requested to make a submission to the ANZ giving information for consideration in their deliberations on whether to fund Gunns highly controversial pulp mill. The Wilderness Society was given two weeks to make this submission. There are numerous complex issues involved in any investigation of forestry operations in Tasmania and the impact they are having on social, economic and environmental values. The conflict over the logging of high conservation value forests in Tasmania has been long (over three decades), and is considered a defining issue that requires resolution. It is the view of THE WILDERNESS SOCIETY and many in the community that the pulp mill represents a project that would lock in the negative impacts of logging for generations to come. It represents a serious threat to the ability of the community, governments, community groups and the logging industry to negotiate a resolution of the logging debate to the satisfaction of all parties. The pulp mill would be a major driver of the long-term maintenance of the status quo – the conflict, the uncertainty and the other negative implications we see today. 5 Neither the State nor the Federal Government assessment of the pulp mill examined the issue of logging or the impact of logging on the forests, water, wildlife and climate. Instead, these assessments deferred responsibility for this to The Regional Forest Agreement (RFA) that the Federal Court found failed to be able to protect certain threatened species of wildlife.1 This is also a document that fails to address climate change and carbon emissions. Indeed the RFA does not even mention the words carbon, climate change or greenhouse and should not form the basis of any assessment of the sustainability of forestry operations. The assessment of the pulp mill has been shambolic. The Resource Planning and Development Commission (RPDC) assessment, agreed to by both governments and Gunns, was abandoned. This independent assessment was to examine the impact of the pulp mill on the forest, assess greenhouse gas emissions and involve public hearings. Significantly, the RPDC was abandoned when it was clear to the panel that the information supplied by the proponent in their impact statement was unsatisfactory, and before the public had had an opportunity to fully contribute and test the proposal. The ultimate assessments adopted by the State and Federal governments were scandalously superficial by comparison. The forests have been left out, climate implications of the pulp mill have been ignored and no public hearings implemented. Community confidence in the assessments is low; opposition to the project is growing and will continue. Community campaigns to protect Tasmania’s forests will also continue and, should the pulp mill be built, constant conflict over the native forests feedstock for the mill can be expected. The Wilderness Society has not been provided with any detail on the scope of ANZ’s assessment plans, the guidelines by which the assessment is being carried out, who is carrying out the assessment or how it will be incorporated into the banks decision- making process. While we are prepared to offer this submission, the ANZ bank’s assessment is NOT seen as an appropriate replacement for the independent assessment once being carried out by the RPDC. The Wilderness Society does not believe the pulp mill project can meet the basic standards of ethical investment and sustainability, the UNPRI’s or the Equator Principles. The Wilderness Society has consistently held a position that is not a blanket opposition to all pulp mills or the timber industry. The Wilderness Society could support a pulp mill provided it was based 100% on existing plantations, be Totally Chlorine Free, sited in an appropriate location and properly assessed with honesty, transparency and public involvement. The Wilderness Society believes that due to the lack of accurate information from the proponent, the abandonment of the agreed assessment process, the sidelining of public involvement and the anticipated social, economic and environmental impacts that the pulp mill will have, the project has no social license. The controversy around the mill is unlikely to go away in the near future. 1 Brown v Forestry Tasmania (No 4) [2006] FCA 1729 (19 December 2006). While this decision was recently overturned on appeal, the Appeal Court’s verdict did not displace this finding. See Forestry Tasmania v Brown [2007] FCAFC 186 (30 November 2007). 6 Given the above, the project should not be funded by ANZ and the bank should begin to actively work with Gunns to assist them in the long overdue reform of the company’s business model and strategic direction.